estudio de impacto a la calidad del aire ambientaldeclaración de impacto ambiental –preliminar...

Declaración de Impacto Ambiental – Preliminar

P l a n t a d e G e n e r a c i ó n d e E n e r g í a R e n o v a b l ey R e c u p e r a c i ó n d e R e c u r s o s

BARRIO CAMBALACHE DE ARECIBO

A P E N D I C E C

Estud io de Impactoa la Cal idad del A i re Ambienta l

N o v i e m b r e 2 0 1 0

Imagine the result

ENERGY ANSWERS ARECIBO, LLC

Renewable Power Generation and Resource Recovery Plant Arecibo, Puerto Rico

Air Quality Analysis Technical Report

PRELIMINARY EIS

OCTOBER 2010

Air Quality Analysis Technical Report Preliminary Environmental Impact Statement

Prepared for:

Energy Answers Arecibo, LLC

Prepared by:

ARCADIS G&M of North Carolina, Inc.

801 Corporate Center Drive

Suite 300

Raleigh,

North Carolina 27607-5073

Tel 919 854 1282

Fax 919 854 5448

Our Ref.:

NCENRGY1.0003

Date:

October 2010

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Table of Contents

Executive Summary 1

1. Introduction 3

1.1 Purpose of this Technical Report 3

1.2 Project Description 3

2. Existing Conditions 5

2.1 Regional Climate 5

2.2 Ambient Air Quality 5

2.3 Methodology for Assessing Existing Conditions 9

2.3.1 NAAQS Attainment Status for the Project Site 9

2.3.2 Hazardous Air Pollutants 11

2.3.3 Regional Haze and Visibility 11

3. Air Quality Impacts 13

3.1 Air Impact Criteria 13

3.2 Applicable Air Regulations and Limitations 13

3.2.1 Federal PSD Permitting 14

3.2.2 New Source Performance Standard (NSPS) Requirements 16

3.2.3 National Emission Standards for Hazardous Air Pollutants 19

3.2.4 Puerto Rico Preconstruction Approvals 19

3.2.5 Puerto Rico Emission Standards 20

3.3 Air Quality Impacts Evaluation 20

3.3.1 Construction Impacts 20

3.3.2 Operating Impacts 21

3.3.3 Air Modeling Methodology 22

3.3.4 Model Selection 23

3.3.5 Model Options 23

3.3.6 Emission Source Description 24

3.3.7 Emission Control Systems 24

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Table of Contents

3.3.8 Emission Source Stack Parameters 25

3.3.9 Emission Rate Calculations 26

3.3.10 Startup and Shutdown Emissions 27

3.3.11 Facility Potential To Emit Summary 27

3.3.12 Good Engineering Practice Stack Height 28

3.3.13 Meteorological Data 29

3.3.14 Land Use and Dispersion Coefficients 29

3.3.15 Receptor Arrays 32

3.3.16 Air Quality Modeling Results 32

3.4 Summary of Air Quality Impacts 34

4. References 36

iii

Table of Contents

Tables

Table 2-1 National Ambient Air Quality Standards (NAAQS) 6

Table 2-2 Actual Ambient Air Quality Measurements 10

Table 3-1 PSD Applicability 15

Table 3-2 NSPS Subpart Da Emission Limits 17

Table 3-3 NSPS Subpart Eb Limits 18

Table 3-4 Ambient Air Quality Standards, PSD Increments,Significant Impact Levels, and Significant Monitoring Concentrations 22

Table 3-5 Source Stack Parameters 25

Table 3-6 Facility Potential Emissions Summary 28

Table 3-7 Surface Characteristics for the Cambalache Site for Summer and Winter Seasons 31

Table 3-8 Model Results - Significant Impact Levels Evaluation 33

Table 3-9 Model Results – Cumulative Impact Levels 34

Figures

1-1 Project Location

1-2 Arecibo Aerial Map and Location of Facility

1-3 Site Layout

3-1 Surrounding Land Use

Attachments

1 Emission Calculations

2 Air Modeling Files on Compact Disc

1

Air Quality Analysis

Energy Answers International, Inc. Preliminary Environmental Impact Statement

Executive Summary

Energy Answers is proposing to construct an electric generating facility capable of

producing approximately 80 megawatts (MW) of renewable power. The facility will be

fueled primarily by Processed Refuse Fuel (PRF), and will have the capability to

supplement PRF with Automotive Shredder Residue (ASR), shredded urban wood

waste, and tire chips. The proposed facility will be located in Arecibo, Puerto Rico.

Existing air quality in Arecibo is monitored by USEPA and the Puerto Rico

Environmental Quality Board (EQB). Based on actual air quality monitoring data and

designations by USEPA, this region is attaining the National Ambient Air Quality

Standards (NAAQS).

Air quality impacts are assessed for this proposed project qualitatively for construction

activities, and quantitatively for the potential emissions when the facility is in operation.

Quantitative impacts are assessed by (1) developing air emission rates of regulated air

pollutants and (2) executing an atmospheric dispersion model to estimate impact to

criteria pollutant concentrations and potential plume visibility from the proposed project.

The USEPA’s AERMOD modeling system was used for this evaluation.

The construction phase activities would likely impact near-field air quality in an

insignificant fashion. Emissions of particulate matter from both the earthmoving

activities and construction equipment exhaust are expected to occur intermittently and

within the immediate vicinity of the project site. Impacts from PM are expected to be

minimal, to be in the immediate vicinity of construction operations, and are expected to

dissipate quickly from the area. Impacts would also we very limited in duration,

occurring just during construction of the facility.

During the operational phase, emissions from the facility would be expected year round

from the sources except during routine shutdown and maintenance activities. The

emission sources proposed for construction and operation include: bottom ash

processing, fly ash processing, oil-fired boilers, cooling towers, and an emergency

generator and fire water pump. Potential maximum emissions were modeled and

compared with the Prevention of Significant Deterioration (PSD) Significant Impact

Level (SIL) thresholds. Maximum ambient air impacts were found to be below the PSD

SIL for all modeled regulated air pollutants except for nitrogen dioxide (NO2) and sulfur

dioxide (SO2) impacts averaged on a 1-hour basis. Impacts below the SIL can be

considered de minimis. For the 1-hour NO2 and SO2, a limited cumulative air

modeling analysis was completed, including other permitted emission sources in the

2



area that could contribute to potential impacts from the proposed Energy Answers

facility. Results for the limited cumulative impact analysis indicate that the potential

maximum air impacts are below the National Ambient Air Quality Standards (NAAQS)

for NO2 and SO2, averaged on a 1-hour basis.

Visibility impacts were simulated and assessed for the stack plume in the immediate

area around the project site and at several distances from the plant site. The visibility

impacts are predicted to be insignificant.

3



1. Introduction

1.1 Purpose of this Technical Report

This document is a technical appendix to the Preliminary Draft EIS (PDEIS) and

assesses, in detail, the impacts of the proposed project on air quality. Impacts to air

quality have potential consequences of increasing concentrations of regulated air

pollutants, degrading visibility, increasing deposition of acid gases to soils and plants,

and stressing ecosystems adversely. Moreover, poor air quality can introduce

additional stresses on the lung functions and respiratory systems in humans, especially

in small children, the elderly, asthmatics, or those with other respiratory ailments. This

report also summarizes the key air regulations that will apply to the project due to the

potential emissions and processes proposed for installation.

1.2 Project Description

Energy Answers Arecibo, LLC (Energy Answers) is an award-winning1, international

designer, developer, owner and operator of environmentally sound resource recovery

systems. Energy Answers is proposing to construct electric generating facility capable

of producing approximately 80 MW of renewable power. The plant will be fueled

primarily with Processed Refuse Fuel (PRF) and have the capability to be

supplemented with Automotive Shredder Residue (ASR), shredded urban wood waste,

and tire chips. The facility will be located in Barrio Cambalache, Arecibo Puerto Rico,

at the site of the former Global Fibers paper mill. Figures 1-1 and 1-2 illustrate the

location of the proposed project site. This project represents a move toward

decreasing landfill of waste, reducing the use of fossil fuel and increasing the

renewable energy supply on the grid in Puerto Rico.

The facility will have the following air emission sources:

• Two (2) spreader-stoker boilers rated at 500 MMBtu/hr each, equipped with three (3) 167 MMBtu/hr fuel oil-fired burners each;

• Ash handling conveyors

• Three storage silos

• One cooling tower with 4 cells (air-cooled condenser type);

1 In 1996, SEMASS was awarded the Ecological Society of America’s Corporate Award for Resource Recycling, recognizing its “record of remarkable reduction

of waste flow combined with environmental concern, done profitably and on a large regional scale.”

4



• One (1) diesel-fired emergency generator set; and

• One (1) diesel-fired emergency fire water pump

The site layout is depicted in Figure 1-3. In addition to power production, the facility will

pre-process municipal solid waste (MSW) into PRF and will process bottom ash and fly

ash on site. PRF processing technology developed by Energy Answers maximizes the

recovery of energy and marketable materials from MSW and other non-hazardous

commercial and light industrial waste streams. This technology has been implemented

at the SEMASS Resource Recovery Facility located in Rochester, Massachusetts.

SEMASS has been in commercial operation since January 1989.

The supplementary fuels (ASR, urban wood waste and TDF) to be used in conjunction

with the PRF will be pre-processed off site by the suppliers.

The proposed facility will include a system for processing bottom ash. This system is

designed to recover ferrous and non-ferrous metals and will produce a granular

material known as Boiler AggregateTM

(BATM

). Boiler Aggregate can be used as filler

for roadway asphalt and in the manufacture of concrete blocks, among many other

applications. Energy Answers also proposes to process the fly ash using a separate

and independent system that will condition it for reuse as a marketable material.

For the purposes of this study, operations at the facility are assumed to occur

continuously, 24 hours per day, 365 days per year although, in actuality, there will be

scheduled shutdowns for maintenance.

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2. Existing Conditions

2.1 Regional Climate

Puerto Rico is generally affected by easterly trade winds, with a daily land/sea breeze

that is found within the wind circulation pattern. Sea breezes tend to blow in an east-

southeast direction across the land during the day. At night, the wind pattern changes

to blow off-shore (land breezes). Precipitation generally falls in the afternoons as small

showers or thunderstorms. Puerto Rico is within the tropical hurricane region of the

Caribbean Sea. Consequently, the island is subject to infrequent tropical storms and

hurricanes from approximately June through November. Due to its tropical location

near the equator, the temperature does not change more than approximately 6°F

between winter and summer months, ranging between 76 °F to 79 °F through the

course of the year.

2.2 Ambient Air Quality

The Clean Air Act, which was last amended in 1990, regulates air quality by requiring

the United States Environmental Protection Agency (EPA) to establish the National

Ambient Air Quality Standards (NAAQS) for airborne compounds that have been

shown to cause degradation to the quality of ambient air. These compounds are

commonly referred to as the “criteria” air pollutants. . The NAAQS are set for various

averaging times at levels which are protective of public health and welfare with an

adequate margin of safety. The primary standards are intended to protect human

health; and the secondary standards are intended to protect public welfare from any

known or anticipated adverse effects associated with the presence of air pollutants,

such as damage to soils, vegetation and wildlife. The criteria air pollutants are carbon

monoxide (CO), nitrogen dioxide (NO2), particulate matter with a diameter of 10

microns or less (PM10), particulate matter with a diameter of 2.5 microns or less (PM

2.5), ozone (O3), sulfur dioxide (SO2), and lead (Pb). In January, 2010 and June, 2010,

the EPA established one-hour average standards for NO2 and SO2, respectively. . The

current NAAQS are presented in Table 2-1.

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Table 2-1 National Ambient Air Quality Standards (NAAQS)

Pollutant Type of Standard Averaging Time Concentration

(µg/m3)

Concentration (ppm)

Carbon Monoxide (CO)

Primary 8-hour (1)

10,000 9

Primary 1-hour (1)

40,000 35

Nitrogen Dioxide (NO2)

Primary and Secondary

Annual Arithmetic Mean

100 0.053

Primary 1-hour (2)

188 0.1

Ozone (O3) Primary and Secondary

1-hour (3)

235 0.12

8-hour (1997 std) (4)

156 0.08

8-hour (2008 std) (4)

147 0.075

Particulate Matter (PM10)


24-hour (5)

150 -

Particulate Matter

(PM2.5)


Annual (Arithmetic Mean)

15.0 -


24 hour 35 -

Sulfur Dioxide (SO2)

Primary Annual Arithmetic

Mean 80 0.03

Primary 24-hour(1)

365 0.14

Primary 1-hour(6)

195 0.075

Secondary 3-hour 1,300 0.5

Lead (Pb)


Quarterly Average 1.5 -


Rolling 3-Month Average

0.15

µg/m3 micrograms per cubic meter

ppm parts per million

(1) Not to be exceeded more than once per year

(2) 3-year average of the 98th percentile of the daily maximum 1-hour average

(3) Applies only in Early Action Compact Areas

(4) 3-year average of the fourth-highest daily maximum 8-hour average

(5) Not to be exceeded more than once per year on average over 3 years

(6) 3-year average of the 99th percentile of the daily maximum 1-hour average

7



The origination and potential effects of each of the criteria pollutants are briefly

described below.

Carbon monoxide (CO) is a colorless gas that can interfere with the body’s ability to

carry and transfer oxygen through the blood to vital organs. CO is predominately

emitted to the atmosphere from combustion sources such as motorized vehicles,

industrial boilers and power plants that are fueled by fossil fuels. Exposure to high

levels of CO can cause headaches, drowsiness, loss of equilibrium, and put stress on

the heart. Typically, the highest concentrations of CO can be observed near congested

intersections, in parking garages, along high-volume roadways, and in urban areas

where buildings and other features can inhibit natural dispersion.

Nitrogen dioxide (NO2) is a brownish gas that, like CO, is predominately emitted as a

product of combustion. Nitrogen in combustion air and fuel is oxidized to nitrogen

dioxide and other oxides of nitrogen (NOx) that subsequently convert to NO2 in the

atmosphere. NOx formation has been found to be largely a function of the combustion

temperatures where the greater the temperature, the more NOx emitted. Atmospheric

NO2 has been found to be a major contributor to the formation of ozone. It can also be

a significant source of nitrogen deposited in streams, ponds, lakes and soils where it

can affect acidity, plant growth and dissolved oxygen levels in water.

Particulate matter (PM) emissions, classified as PM10 and PM2.5, originate from

many types of industrial processes and from fossil fuel combustion, including diesel

powered motor vehicles. Roadway construction activities also produce PM10 and

PM2.5 emissions, although PM2.5 emissions are primarily formed from diesel engines

rather than in dust generated from earthwork cut-and-fill activity. PM2.5 can also form

from secondary atmospheric reactions of organic and inorganic compounds. Generally,

particulate matter is a category made up of a combination of solid particles, aerosols

and condensable compounds. Examples include dust, soot, smoke, metal fume, acid

fume, ammonium sulfate and other carbonaceous matter. When inhaled, these

materials can stress the respiratory system and heart. Particulate matter suspended in

the atmosphere can also have a light-scattering effect that reduces visibility and can

cause a visible haze.

Ozone (O3) is a secondary pollutant formed by atmospheric reactions involving volatile

organic compounds (VOC) and NOx. Its formation is a complex process that depends

on the intensity and spectral distribution of sunlight, atmospheric mixing and other

atmospheric processes as well as the concentrations of NOx and VOC in ambient air.

Ozone is highly reactive gas that can irritate and damage lung tissue, oxidize plant

8



tissue, stunt plant growth and reduce agricultural crop yield. Since ozone formation

occurs as a function of secondary reactions in the atmosphere, ozone is understood to

be a pollutant that is monitored and controlled on a regional scale. Given the multitude

of sources of NOx and VOC emissions throughout the project study area and

throughout the region, and the inherent variability of sunlight and meteorological factors

that contribute to ozone formation, it is beyond the scope of this evaluation to attempt

to quantify the potential effects that this project could have on ozone concentrations in

the study area.

Sulfur dioxide (SO2) emissions originate primarily from fossil fuel combustion at

electrical utilities, industrial plants and, to a smaller extent, in diesel powered motor

vehicles including locomotives. At combustion sources, SO2 emissions occur as a

direct function of the sulfur present in the fuel, where sulfur is oxidized in the

combustion process to SO2. When vented to the atmosphere, SO2 emissions can

react with water to form sulfuric acid and sulfate that eventually gets deposited to soils

and waterways as particles or droplets. Similar to nitrogen deposition, sulfur deposition

can increase the acidity of soils and water which has the effects of depleting nutrients

and reducing viability. In addition, SO2 concentrations in ambient air have been found

to cause acute respiratory symptoms and diminished ventilator function, especially in

children.

Lead (Pb) is a metal found naturally in the environment as well as in manufactured

products. The major sources of lead emissions have historically been motor vehicles

(such as cars and trucks) and industrial sources. As a result of EPA's regulatory efforts

to remove lead from gasoline, emissions of lead from motor vehicles dramatically

declined in the last two decades. Today, the highest levels of lead in air are usually

found near lead smelters. Other stationary sources are waste incinerators, utilities, and

lead-acid battery manufacturers.

In humans, Pb gets distributed throughout the body in the blood and accumulates in

the bones. Depending on the level of exposure, lead can adversely affect the nervous

system, kidney function, immune system, reproductive and developmental systems

and the cardiovascular system (e.g., high blood pressure and heart disease). Lead

exposure also affects the oxygen carrying capacity of the blood. Infants and young

children are especially sensitive to even low levels of lead, which may contribute to

behavioral problems, learning deficits and lowered IQ.

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2.3 Methodology for Assessing Existing Conditions

Existing air quality conditions were evaluated primarily on the basis of actual

monitoring data collected for criteria air pollutants. Depending on whether monitoring

data indicate that the ambient concentrations of the criteria pollutants meet the

NAAQS, EPA designates geographical areas as “attainment,” “non-attainment,” or

“unclassifiable” for each criteria pollutant. An attainment designation indicates that the

area or region has ambient concentrations that are below the NAAQS, whereas a

designation of “non-attainment” is given for areas that violate or have contributed to

violations of the NAAQS. “Unclassifiable” areas are those where a positive designation

cannot be made due to insufficient monitoring data.

2.3.1 NAAQS Attainment Status for the Project Site

The USEPA has classified the Municipality of Arecibo and the surrounding area as

being in compliance with the NAAQS (attainment) for each criteria pollutant. The

USEPA and Puerto Rico Environmental Quality Board maintain air quality monitoring

stations that measure actual ambient air concentrations of the criteria pollutants.

Based on the recorded data collected at the ambient air monitors for Puerto Rico, the

following table lists the actual recent monitored values recorded for the area as

reported by the USEPA AirData database.

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Table 2-2 Actual Ambient Air Quality Measurements

(1) Value represents the maximum recorded concentration in 2005, however, the NAAQS is the 3-year average of the annual 99

th percentile of daily maximum 1-hour measurements. The 1 hour SO2 standard was recently

finalized by USEPA in 2010. Official ambient monitoring values for the 1 hour SO2 standard have not yet been published.

(2) Value represents the maximum recorded concentration in 2006, however, the NAAQS is the 3-year average

of the annual 98th percentile of daily maximum 1-hour measurements. The 1-hour NO2 standard was recently

finalized by USEPA in 2010. Official ambient monitoring values for the 1-hour NO2 standard have not yet been published.

Monitor ID Year Municipality Pollutant

Averaging

Period

Concentration

(µg/m3)

NAAQS

(µg/m3)

721270003 2008

San Juan PM10 24-hour 78

150

720010002 2008 Adjuntas PM2.5 24-hour

Annual

10.5

5.21

35

15

720170003 2005 Barceloneta SO2

1-hour

3-hour

24-hour

Annual

86.5(1)

39.3

15.7

7.86

195

1300

365

80

720330008 2006 Catano NO2 1-hour

Annual

72(2)

18.9

188

100

721270003 2008 San Juan CO 1-hour

8-hour

4255

2645

40,000

10,000

721270003 2008 San Juan Pb 3-month

average 0.05 0.15

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2.3.2 Hazardous Air Pollutants

In addition to the criteria air pollutants, the Clean Air Act identified 188 chemical

compounds or groups of compounds as being toxic to human health or the

environment referred to as hazardous air pollutants (HAP). Several of these

compounds are predicted to be present in the exhaust from the proposed facility;

however, there are no ambient air quality standards for these compounds except for

lead. EPA has taken a technology-based approach for regulating HAPs. Standards for

HAP are issued under the National Emissions Standards for Hazardous Air Pollutants

(NESHAPs) under which Maximum Achievable Control Technology (MACT) standards

are imposed on qualifying specific emission source categories that emit HAP. Energy

Answers proposes to install an air quality control system that will meet or exceed the

applicable MACT standards for HAP compounds.

2.3.3 Regional Haze and Visibility

Regional haze is a reduction in visibility caused by the combined effect of particles and

gases in the atmosphere that scatter and absorb light over a wide geographic area.

The reduction in visual clarity that results (haziness) is technically referred to as “light

extinction.” Evaluations of both particles and gases indicate that the presence of fine

particles (PM2.5) in the atmosphere is the primary cause of regional haze. These

particles consist of ammonium sulfate, organic carbon, elemental carbon, ammonium

nitrate, and soil and can be present as a result of natural processes or human activity.

Under the Clean Air Act Regional Haze Program, visual air quality in 156 Class I areas

across the country is being monitored. The states with Federal Class I areas are

required to establish a baseline visibility value 2000-2004 from which future

improvements will be gauged. Since visibility conditions are not constant, but rather

vary with changing natural processes that can lead to high short-term impacts, the rate

of improvement in visual quality is measured over a long-term averaging period (5

years). Specifically, visual quality is measured in terms of the 20 percent clearest

(best) days and the 20 percent haziest (worst) days over a 5-year period. The ultimate

goal of the Regional Haze Program is to restore visual clarity to the level defined as the

“natural visibility conditions” for the 20 percent haziest days and prevent the 20 percent

best days from getting worse. Natural visibility conditions represent the long-term

degree of visibility that is estimated to exist in the absence of human-caused effects.

Visibility conditions, progress goals, and changes in natural visibility conditions are

expressed in terms of deciview (dv) units, per 40 CFR 51.308(d)(1). The deciview is a

12



unit of measurement of haze that indicates changes in perception of haziness (derived

from light extinction). The approved methodology for calculating visibility in Federal

Class I areas was established by the Interagency Monitoring of Protected Visual

Environments (IMPROVE). Concentrations of particulate matter species are summed

in conjunction with the relative humidity averages for a given area.

States are required to establish baseline values using visibility data collected from

2000-2004 to develop strategies for improving visibility in the Federal Class I areas,

and to implement these strategies in a State Implementation Plan (SIP) for Regional

Haze. The SIP submittals were due no later than 2008. Because regional haze is due

to a wide number of influencing human activities and air currents that do not recognize

state boundaries, many states are working together in regional partnerships to

establish policies and goals for regional haze improvements (e.g., VISTAS).

The closest designated PSD Class I area is Virgin Islands National Park, located on

the island of St. John, approximately 170 km east of the proposed site. Given the

relatively large distance, visibility modeling would not yield reliable or meaningful

results. Therefore, no further analysis for potential Regional Haze impacts was

completed.

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3. Air Quality Impacts

3.1 Air Impact Criteria

Impacts to air quality from construction or operation would require mitigation if one of

the following occurred:

Emissions from the proposed project are predicted to result in a violation

of federal or Puerto Rico Environmental Quality Board air quality

standards

Emissions from the proposed project qualifying as a major source of air

pollution

Emissions from the proposed project predicted to contribute to a violation

or worsen an existing violation of the NAAQS

Emissions from the proposed project predicted to cause incremental

increases of air quality pollutants exceeding the allowable limit under the

Prevention of Significant Deterioration (PSD) regulations for Class I and

II areas

An air quality analysis, including completion of an inventory of potential emissions and

conducting dispersion modeling, serves as the basis for evaluating the potential air

quality impacts from the proposed facility.

3.2 Applicable Air Regulations and Limitations

The proposed project will be subject to both federal and Puerto Rico air quality control

regulations and emission limits. Emissions from the proposed facility will be limited to

comply with regulations under the following programs:

Federal New Source Review PSD regulations for major new sources including:

o Site-specific Best Available Control Technology (BACT) emission

limits

o Air Dispersion Modeling Impact Analysis to quantify the potential

change in ambient air quality from the proposed facility

Federal New Source Performance Standards (NSPS)

National Emission Standards for Hazardous Air Pollutants (NESHAP)

14



Puerto Rico preconstruction approvals

Puerto Rico emission standards

A description of these applicable requirements is given below.

3.2.1 Federal PSD Permitting

Based on the size of the facility, and in accordance with Puerto Rico and federal

regulations, Energy Answers must obtain a Prevention of Significant Deterioration

(PSD) air permit prior to beginning construction, in accordance with permitting

procedures per 40 CFR Part 52.21 and PR Rule 203. This permit application will be

submitted to the United States Environmental Protection Agency Region 2 for approval

to construct and operate the proposed facility. The proposed project area location is

currently designated as in attainment of National Ambient Air Quality Standards

(NAAQS) for all criteria pollutants. The attainment status for the area is an important

factor in determining the necessary review procedures for the proposed project.

The USEPA adopted PSD regulations (40 CFR 51) pursuant to the CAA Amendments

of 1977 that outlined a detailed PSD program. The objectives of the PSD permit

program regulations are (1) to ensure that economic growth will occur in harmony with

the preservation of existing clean air resources; (2) to protect ambient air quality from

degrading as a result of increased emissions from new major stationary sources or

from expanding existing emission sources; and (3) to preserve air quality in special

areas such as national parks and wilderness areas. The primary provisions of the PSD

regulations require new major stationary sources and major modifications to be

examined prior to construction to ensure compliance with the NAAQS and applicable

PSD air quality allowable “increments”. The PSD program also requires new major

projects to install the best available control technology (BACT) to reduce its emissions.

A new source of air pollution is subject to the PSD regulations if it is proposed to be

located in an attainment area and it qualifies as a major stationary source. A major

stationary source is any source included on a list of 28 specified categories which has

the potential to emit 100 tons per year (tpy) or more of any pollutant regulated under

the CAA and any unlisted sources with emissions of a regulated pollutant of greater

than 250 tons per year (tpy). The proposed Energy Answers facility falls within a PSD

Source Category and is subject to the 100 tons per year major source threshold.

Based on the proposed facility’s potential to emit, it will be a PSD major source subject

to the PSD preconstruction review and permitting procedures for several criteria

pollutants and other regulated air pollutants. Table 3-1 summarizes the PSD

applicability by emission rate.

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Table 3-1 PSD Applicability

Pollutant

PSD Major Source

1

(tons/year)

Potential Emission Rate

2

(tons/year) PSD Review

Required

Carbon Monoxide 100 702 Yes

Nitrogen Oxides 100 347 Yes

Sulfur Dioxide 100 256 Yes

Particulate Matter (PM) 100 46.1 No

Particulate Matter < 10 microns (PM10) 100 45.1 No

Particulate Matter < 2.5 microns (PM2.5) 100 24 No

Volatile Organic Compounds 100 63 No

Lead 0.6 0.25 No

Asbestos 0.007 N/A No

Beryllium 0.0004 0.003 Yes

Fluorides (as HF) 3 13 Yes

Mercury 0.1 0.06 No

Sulfuric Acid Mist 7 55 Yes

Hydrogen sulfide (H2S) 10 N/A No

Total Reduced Sulfur Compounds 10 N/A No

Vinyl chloride 1 N/A No

Municipal Waste Combustor Organics (measured as total tetra-thru octa-chlorinated dibenzo-p-dioxins and dibenzofurans)

3.5E-6 4.5E-5 Yes

(1) Source: 40 CFR 52.21

(2) Estimated maximum annual emission rates assume both boilers operate at a heat input rate of 500

MMBTU/hr for 8760 hours

The EPA Region 2 office is responsible for issuing the PSD permit for Energy Answers

and other major sources in Puerto Rico. As part of the PSD permitting program,

Energy Answers must evaluate air pollution control technologies that are available for

each pollutant that will potentially be emitted in “significant” quantities. A “top-down”

evaluation must be completed to determine which emissions control technology is the

Best Available Control Technology (BACT) for each pollutant. In addition to the BACT

analysis, Energy Answers is required to complete an air quality impacts analysis and

secondary impacts analysis as part of the PSD application process. The analyses

require that the applicant use USEPA-approved air dispersion modeling methods to

predict the maximum ambient air impacts of the regulated air pollutants.

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3.2.2 New Source Performance Standard (NSPS) Requirements

The New Source Performance Standards (NSPS), codified under 40 CFR Part 60,

specify the minimal performance requirements for certain new or modified air emission

sources. The proposed Energy Answers facility will be subject to the following NSPS

under 40 CFR Part 60:

• Subpart A – General Provisions • Subpart Da – Electric Utility Steam Generating Units • Subpart Eb – Large Municipal Waste Combustors • Subpart IIII – Stationary Compression Ignition Internal Combustion Engines

A summary of the requirements of each of these rules to the proposed facility is given

below:

3.2.2.1 Subpart A – General Provisions

Certain provisions of 40 CFR Part 60 Subpart A (General Provisions) apply to the

owner or operator of any stationary source subject to a NSPS. Based on the proposed

plant design and equipment specifications, the facility will be subject to NSPS Subparts

Da, Eb and IIII. The specific requirements of each of these rules are described in

further detail in the subsections below. In addition to the emission limits and operating

requirements provided within each individual NSPS, Energy Answers is required to

comply with General Provisions of Subpart A. The applicable General Provisions

include §60.7 (Initial notification and recordkeeping); §60.8 (Performance Tests);

§60.11 (Compliance with standards and maintenance requirements); §60.13

(Monitoring requirements); and, §60.19 (General notification and reporting

requirements).

3.2.2.2 Subpart Da – Standards of Performance for Electric Utility Steam Generating

Units

Subpart Da regulations apply to (fossil-fuel fired) electric utility steam generating units

for which construction, modification, or reconstruction commenced after September 18,

1978, and which have a heat input capacity of greater than 250 MMBtu/hour. Since the

fuel oil burners will collectively have a heat input greater than 250 MMBtu/hr (each is

rated at 167 MMBtu/hr) and meet the “steam generating unit” definition, they will be

subject to NSPS Subpart Da. Subpart Da specifies emission limitations, monitoring,

recordkeeping and reporting requirements for PM, NOx, SO2, and opacity.

17



Table 3-2 NSPS Subpart Da Emission Limits

Parameter Subpart Da Limit Operating Scenario Averaging Period

Particulate Emissions

0.14 lb/MWh or 0.015

lb/MMBtu

Any Fuel Continuous or 0.03 lb/MMBtu and

99.9% reduction

or 99.8% reduction

Opacity 20 %

Any Fuel 6-minute average

CEMS for PM

SO2 1.2 lb/MMBtu Solid Fuel

30 day rolling average

0.54 lb/MMBtu Liquid or gaseous Fuel

NOx 1.0 lb/MWh Any Fuel 30 day rolling average

3.2.2.3 Subpart Eb – Standards of Performance for Large Municipal Waste Combustors

NSPS Subpart Eb applies to individual Municipal Waste Combustor (MWC) units with

capacities greater than 225 mega grams per day (approximately 250 tons/day). Under

40 CFR 60.51b, municipal solid waste is defined to include “refuse-derived fuel.” Since

the proposed facility will use an average of 2,100 tons per day (1,050 tons per day per

boiler) of processed refuse fuel, the provisions of Subpart Eb will apply. Emission

standards are given for metals, opacity, acid gases, dioxins and furans, NOx, and

fugitive emissions from ash handling. Each of the emission limits are listed in Table 3-

3. Subpart Eb also provides requirements that the owner or operator implement Good

Combustion Practices for minimizing emissions of CO, dioxins and furans, and

particulate matter. Additionally, Subpart Eb specifies requirements for siting the facility,

implementing management planning, preparing a materials separation plan, and

conducting operator training.

18



Table 3-3 NSPS Subpart Eb Limits

Parameter Subpart Eb Limit Units Averaging Period

Particulate Matter 20 mg/dscm

NOx 150 Ppmvd daily 24-hour

arithmetic average

CO 150 Ppmvd

SO2

30 Ppmvd

daily 24-hour

geometric mean 80 % reduction

Cadmium 10 ug/dscm

HCl

25 Ppmvd

95 % reduction

Lead 140 ug/dscm

Mercury 28 ug/dscm

Total Dioxons / Furans 13 ng/dscm

Opacity 10 Percent 6-minute average

Fugitive Emissions from Ash

Handling

5 Percent 3 hour observation

period

Load Level 110

percent of maximum load

during dioxin/furan test

4-hour block

average

PM Control Device Inlet

Temperature 17

degrees Centigrade

above maximum temp

during dioxin/furan test

4-hour block

average

19



3.2.2.4 Subpart IIII – Standards of Performance for Stationary Compression Ignition

Internal Combustion Engines

Subpart IIII applies to stationary compression ignition (CI) internal combustion engines

(ICE) that commence construction after July 11, 2005, where the CI ICE are

manufactured after April 1, 2006 (for engines which are not fire pumps) or after July 1,

2006 (for NFPA fire pumps). This subpart will be applicable to the facility’s emergency

generator and fire water pump.

3.2.3 National Emission Standards for Hazardous Air Pollutants

The proposed Facility will have the potential to emit greater than 10 tons per year of

any single HAP. Therefore, the facility will be a major source under Section 112 of the

CAA. Section 112 provides technology-based standards that reduce emissions of HAP

nationally. The NESHAPs are codified in 40 CFR Part 63. The proposed Renewable

Energy Plant includes an air quality control system that will achieve a level of control

on HAP that can be considered “new source MACT” level of control. Specifically, the

Turbosorp®, in combination with the fabric filters, is designed to reduce emissions of

HCl, HF, and particulate HAP. Similarly, the activated carbon injection system, in

combination with the fabric filters, is expected to reduce potential mercury and

dioxins/furans to levels of control that can be considered to be MACT. Finally, organic

HAPs, which generally can be emitted as a result of incomplete combustion, will be

minimized by maintaining high (combustion) temps and monitoring CO levels via a

CEMS.

Additionally, Energy Answers will comply with 40 CFR 60, Subpart Eb which includes

emission standards for HAP compounds, and generally was developed based on a

procedure similar to MACT.

The Reciprocating Internal Combustion Engine (RICE MACT) applies to the diesel

engines in the future as re-proposed by the USEPA on March 5, 2009. This rule is

codified in 40 CFR 63, Subpart ZZZZ. Generally, Energy Answers will be installing

new units which will be manufactured to comply with this rule.

3.2.4 Puerto Rico Preconstruction Approvals

Puerto Rico Rules 201, 202 and 203 describe the application content and

Environmental Quality Board (EQB) review procedures for facilities proposing to

construct a new major stationary emission source. Rule 201 specifically describes the

Location Approval requirement in which a facility must prepare a demonstration that

20



shows the proposed facility would not cause or contribute to a violation of the NAAQS.

The proposed operations and air quality control equipment must be described and the

emissions modeled in accordance with the provisions of Rule 202, unless otherwise

exempt. Emission offsets are allowed, if necessary, for a source to demonstrate that

impact will remain below the NAAQS. A public hearing must be offered as part of the

location approval process. EQB makes a final determination of location approval

within one year of receiving a complete application.

Per the exemptions allowed under paragraph (I) of Rule 201, the proposed Energy

Answers facility is not required to include a modeling analysis as part of its Location

Approval application since it will utilize more that 50 percent refuse derived fuel.

Nevertheless, Energy Answers is completing an air quality impact modeling analysis

under the requirements to obtain a preconstruction PSD air permit from the EPA and

will also file an application to obtain a permit to construct from the EQB per Rule 203.

3.2.5 Puerto Rico Emission Standards

Rules 401 through 417 provide emission standards that apply to permitted facilities.

Specific limitations are set on visible emission in Rule 403 where opacity is limited to

20 percent on a 6-minute average. Rule 406 specifies a limit on particulate emissions

from fuel burning equipment of 0.30 pounds per million BTU. Rule 407 specifies an

allowable emission rate of particulate matter from non-fuel burning equipment (e.g.

storage silos and conveyors) based on the process weight rate through the equipment

or emission source. The emission standards under these rules are overlapped by the

emission limits that will be enforceable under the PSD permitting procedure. The PSD

limit is expected to be equally stringent or more stringent than what is allowed by the

Puerto Rico Air Quality Rules including Rules 403, 406, and 407. Therefore, when

Energy Answers operates in compliance with the terms and conditions of its PSD

permit, it will also operate in compliance with the Puerto Rico air quality Rules.

3.3 Air Quality Impacts Evaluation

3.3.1 Construction Impacts

Emissions of regulated air pollutants will occur at the site during the construction

activities. Specifically, construction equipment will produce emissions from the diesel

and gasoline fired engines, and the earth-moving activities will generate fugitive

emissions of particulate matter. These emissions are temporary and at ground level,

which results in potential impacts that are localized and insignificant. Energy Answers

proposes to minimize the potential emissions during construction by implementing best

21



management practices, such as using a water suppressant, for controlling fugitive dust

generated from the earthwork activities and construction equipment movements. In

addition, the construction equipment used will need to conform to USDOT and EPA

non-road diesel emission standards, which minimize emissions of diesel particulate

matter and other pollutants from the engine exhaust.

3.3.2 Operating Impacts

The majority of emissions will occur during typical operation once sources have been

constructed. Pollutants expected to be emitted under operating conditions were

quantified for evaluation in an air modeling analysis to predict impacts to air quality.

Facilities that require review under the PSD regulations must conduct an air quality

impact analysis, using air dispersion modeling methods, for each pollutant emitted in

major (significant) quantities. The purpose of the analysis is to demonstrate whether

the proposed installation will meet applicable NAAQS and PSD allowable increments.

In the event that predicted ambient air impacts are below Significant Impact Levels

(SIL) defined in the regulations, no further analysis is necessary. SILs are a screening

tool used to determine whether a proposed source’s emissions will have a “significant”

impact on air quality in the area. If an individual facility is expected to result in an

increase in air quality impacts less than the corresponding SIL, its impact is said to be

de minimis and the applicant is not required to perform a more comprehensive,

cumulative modeling analysis. A cumulative analysis involves measuring the impact of

the new facility in addition to impacts from other existing sources in the area. This

modeling analysis included a comparison of predicted impacts to the SILs. A limited

cumulative modeling analysis was completed for emissions that exceeded the SILs.

The modeling results are also important when determining whether ambient air

monitoring will be required for the project. The PSD regulations also require an

applicant to conduct actual ambient air monitoring before construction can be

approved. Similar to the SIL, the PSD regulations include Significant Monitoring

Concentrations (SMC), which are the levels above which the permitting authority

requires one year of pre-construction ambient air monitoring. If the dispersion model

predicts ambient concentrations below the SMC, the source’s impact may be

considered de minimis and the reviewing authority can exempt the application from

preconstruction ambient monitoring.

The NAAQS, PSD allowable increment, SIL and SMC values are defined in 40 CFR

Part 50 and are listed in Table 3-4.

22



Table 3-4 Ambient Air Quality Standards, PSD Increments, Significant Impact Levels, and Significant Monitoring Concentrations

Pollutant Averaging

Period

Ambient Air Quality Standards

NAAQS(µg/m3)

PSD Increment

Class II (µg/m

3)

SIL (µg/m

3)

SMC (µg/m

3)

SO2

1-hour 1195 none 8 none

3-hour 1,300 512 25 none

24-hour 365 91 5 13

Annual 80 20 1 none

PM10 24-hour 150 30 5 10

Annual Revoked 17 1 none

PM2.5

24-hour 35 9 1.32 4.0

Annual 15 4 0.32 none

CO 1-hour 40,000 none 2,000 none

8-hour 10,000 none 500 575

NO2

1-hour 1883 none 8 none

Annual 100 25 1 14

Pb 3-month 1.5 none none 0.1

Fluorides 24-hour None none none 0.25

1. EPA issued the new 1-hour SO2 NAAQS in June 2010. At the same time, EPA revoked the 24-hour and annual SO2 NAAQS, although they will remain in effect temporarily until further rulemaking is finalized.

2. PM2.5 SIL, increments, and SMC were finalized on September 29, 2010. The effective date of the final rule is pending publication in the Federal Register, which has not occurred as of this writing.

3. EPA issued the new 1-hour NO2 NAAQS in February 2010.

3.3.3 Air Modeling Methodology

In accordance with the procedures outlined in 40 CFR Part 51 Appendix W Guideline

on Air Quality Models and PR Rules 201 and 202 an air dispersion modeling analysis

was performed to evaluate the likely effects that the proposed plant emissions may

have on ambient air quality. An air dispersion model incorporates the source-specific

parameters such as stack height, exit temperature, flow rate, and spatial location with

meteorological conditions and building geometry to approximate the dispersion

characteristics of an exhaust plume across a study area. Dispersion modeling is

used primarily to estimate the ambient concentration of the regulated air constituents

23



within the surrounding air. The technical approach used to analyze the potential

ambient air quality impacts from the proposed facility was developed in accordance

with accepted practices and USEPA guidance.

3.3.4 Model Selection

For the purposes of this air dispersion modeling study, the EPA Regulatory Model

AERMOD was used to predict the maximum ambient air quality concentrations of the

regulated emissions. AERMOD (version 09292) was selected to predict ambient

concentrations in simple, complex and intermediate terrain surrounding the proposed

facility. The AERMOD Modeling System includes preprocessor programs (AERMET

(version 06341), AERSURFACE (updated January 2008), and AERMAP (version

09040)) to create the required input files for meteorology and receptor terrain

elevations. AERMOD is the recommended model in USEPA’s Guideline on Air Quality

Models (40 CFR Part 51, Appendix W) (USEPA 2005).

The land use data available through the United States Geological Survey (USGS) for

Puerto Rico are not considered representative of the current conditions. Therefore, per

USEPA direction, the AERSURFACE utility was not proposed to be used for this

project. Rather, surface roughness numbers were calculated per the ADEC Guidance

for AERMET Geometric Means, which was developed by the State of Alaska. This

guidance provides the equations needed to calculate the surface roughness numbers

for inclusion in AERMET. This guidance essentially replicates the procedure followed

by AERSURFACE utility program, but with the land use data determined through

satellite images and photographs. Further details regarding the surface parameters

are given in section 3.3.14.

3.3.5 Model Options

The AERMOD “regulatory default” option was selected for this analysis. This model

option directs AERMOD to use the following techniques:

• The elevated terrain algorithms requiring input of terrain height data for

receptors and emission sources;

• Stack tip downwash (building downwash automatically overrides);

• The calms processing routines;

• Buoyancy-induced dispersion; and

• The meteorological processing routines that account for missing data.

24



3.3.6 Emission Source Description

The proposed Energy Answers plant will install and operate the following air emission

sources:

• Two (2) spreader-stoker boilers with a heat input rating of 500 MMBTU/hr

each, equipped with three (3) 167 MMBTU/hr No 2 Fuel Oil-fired burners

each;

• MSW receiving, processing and PRF storage operations;

• Fly and bottom ash transfer, processing and storage operations;

• Storage Silos (lime, pulverized activated carbon, flyash);

• One (1) cooling tower, with 4-cells (air-cooled condenser type);

• One (1) diesel fuel-fired emergency generator set; and

• One (1) diesel fuel-fired emergency firewater pump

3.3.7 Emission Control Systems

Energy Answers is committed to installing advanced air quality control systems on its

power plant that qualifies as the Best Available Control Technology (BACT) for its

operations. Independently operating air quality control systems will be proposed for

each boiler, potentially consisting of the following technologies:

An activated carbon injection system to remove heavy metals, including

mercury and dioxins/furans;

A Turbosorp Dry Circulating Fluid Bed Scrubber system to remove acid

gases using lime injection

A fabric filter (baghouse) to control particulate emissions (including metals);

and,

A regenerative selective catalytic reduction (RSCR) system for reducing

emissions of nitrogen oxides (NOx).

The boilers are expected to operate near the design heat input rating of 500

MMBTU/hr each. For the purposes of this air quality impact analysis, this is defined as

the 100 percent load scenario. In addition to the 100 percent load, Energy Answers

25



evaluated the 110 percent load (550 MMBTU/hr each) as representing the short-term

maximum operating conditions.

3.3.8 Emission Source Stack Parameters

The air dispersion model requires the input of certain site-specific data to produce

results that are representative of the actual site conditions. These data include stack

coordinates, height, diameter, emission rates exit temperature and exit flow rate. Table

3-5 provides a list of these data estimated for the maximum short term (110% firing

rate) and average sustainable (100% firing rate) operating scenarios.

Table 3-5 Source Stack Parameters and Emission Data

Emission Rate (g/sec)

Source ID Vent # Boiler Load

Stack Height (m)

Stack Diam (m)

Exit Velocity

(m/s)

Temp

(K) CO NOx SOx PM10

Boiler1

P-5

110%

95.52

2.13

32.81 431 11.09 5.46 4.06 0.634

100% 28.82 431 10.08 4.97 3.69 0.577

Boiler2

P-6

110%

95.52

2.13

32.81 431 11.09 5.46 4.06 0.634

100% 28.82 431 10.08 4.97 3.69 0.577

Cool1 P-11 N/A 10.7 9.14 7.62 311 N/A N/A N/A 0.0054

Cool2 P-12 N/A 10.7 9.14 7.62 311 N/A N/A N/A 0.0054

Cool3 P-13 N/A 10.7 9.14 7.62 311 N/A N/A N/A 0.0054

Cool4 P-14 N/A 10.7 9.14 7.62 311 N/A N/A N/A 0.0054

MSW1 P-1A N/A N/A N/A N/A N/A N/A N/A N/A N/A

MSW2 P-1B N/A N/A N/A N/A N/A N/A N/A N/A N/A

PRF P-2 N/A N/A N/A N/A N/A N/A N/A N/A N/A

Ash P-15 N/A 20+/- 1.52 15.52 311 N/A N/A N/A 0.0322

Trans1 P-3 N/A 16.5 0.83 17.47 311 N/A N/A N/A 0.0216

Trans2 P-4 N/A 16.5 0.83 17.47 311 N/A N/A N/A 0.0216

Silo 1 P-9 N/A 13.1 0.18 18.59 311 N/A N/A N/A 0.00108

Silo 2 P7 N/A 30.5 0.18 18.59 311 N/A N/A N/A 0.00108

Silo 3 P-8 N/A 38.1 0.18 18.59 311 N/A N/A N/A 0.00108

Gen P-16 N/A 10.0 0.152 49.2 779 1.097 2.70 0.00113 0.028

FWP P-17 N/A 10.0 0.152 49.2 708 0.278 0.32 0.00021 0.014

26



3.3.9 Emission Rate Calculations

Emission rate calculation were developed using equipment specifications, published

emission factors, and the approximate design parameters for the proposed facility.

Where appropriate, the emission calculations were based upon the proposed BACT

performance levels that are guaranteed by the manufacturers of the equipment and

control devices, and, therefore, represent conservative estimates of actual emissions.

3.3.9.1 Processed Refuse Fuel (PRF) Boilers

The boilers will emit NOx, SOx, PM, and CO. The technical approach for calculating

the maximum potential to emit from the two PRF-fired boilers was to use the proposed

BACT emission limits and control equipment vendor guaranteed outlet concentrations

with the design outlet air flow specifications. Emissions representing a short-term

maximum (110%) firing rate and a typical sustained (100%) firing rate were calculated

and are provided in Attachment 1. Maximum hourly and annual emission rates are

detailed in the table. For annual potential-to-emit (PTE) calculations, the two boilers

were assumed to operate continuously for 8,760 hours per year at 100% design

capacity.

3.3.9.2 Cooling Tower

The cooling tower is a potential source of particulate matter emissions. The maximum

emission rates for PM, PM10, and PM2.5 were calculated based upon the equations and

methods in AP-42 Chapter 13.4, design flow specifications, and actual water quality

test data obtained for the potential cooling water supply source (Cano Triburones).

These emission rates are further refined via a method developed by Reisman and

Frisbie that is specific to cooling towers. The cooling towers are assumed to operate

continuously for 8,760 hours per year at 100% design capacity for PTE calculations.

The emission calculations for the cooling tower are provided in Attachment 1.

3.3.9.3 Lime and Ash Handling

Loading, unloading, and conveying activities associated with receiving, storing, and

handling lime for the Turbosorp and ash from the boilers (both fly ash and bottom ash)

can potentially result in emissions of particulate matter. Energy Answers proposes to

control the potential emissions of particulate matter from its lime storage and ash

handling operations by using fabric filters (baghouses). Emission rates of particulate

matter are, therefore, developed based on the performance specifications given for the

27



fabric filters and the maximum design exhaust air flow rates through the baghouses.

Attachment 1 provides the calculations of particulate from the lime and ash handling

activities.

3.3.9.4 Emergency Generator

The proposed emergency diesel generator will be approximately 670 horsepower.

This unit will be new and, therefore, subject to the emission limits provided in NSPS

Subpart IIII and NESHAP Subpart ZZZZ. These emission standards were

conservatively used in conjunction with the emergency generator operating limit of 500

hours per year that EPA recommends using for emergency equipment in order to

estimate the maximum potential to emit. Emissions of individual hazardous air

pollutants are also estimated using conservative emission factors given in AP-42.

Attachment 1 provides the emission rate calculations for the emergency generator.

3.3.9.5 Fire Water Pump

Energy Answers proposes to install one fire water pump with an approximate rating of

350 horsepower. Similar to the emergency generator, this unit will be new and,

therefore, subject to the emission limits provided in NSPS Subpart IIII and NESHAP

Subpart ZZZZ. These emission standards were used in conjunction with the operating

limit of 500 hours per year to estimate the maximum potential to emit since it will be

manufactured to meet these limits. Additional emissions are estimated using

conservative emission factors given in AP-42. Attachment 1 provides the emission

rate calculations for the emergency generator.

3.3.10 Startup and Shutdown Emissions

Each boiler will be equipped with three fuel oil burners rated at 167 MMBTU/hr each.

Startup and shutdown procedures will require No. 2 fuel oil to be burned for

approximately 12 hours. Emission rates during this period are summarized in

Attachment 1. Emissions during startup and shutdown episodes will be vented through

the control equipment which will actively minimize emissions.

3.3.11 Facility Potential To Emit Summary

Table 3-6 summarizes the potential annual emissions from the proposed facility as

derived using the methods described above.

28



3.3.12 Good Engineering Practice Stack Height

Prior to modeling, each emission point stack height must be evaluated relative to what

is considered Good Engineering Practice (GEP) stack height, identified in federal

regulation 40 CFR 51. GEP stack height is a measure for evaluating whether nearby

buildings and outlying topography significantly affect the air dispersion patterns from

the modeled source, resulting in conditions of aerodynamic downwash, including

building cavity and wake effects. The building cavity is a region of turbulent, re-

circulating airflow which extends downwind a distance of approximately three building

heights from the structure. The building wake is a turbulent zone that extends from the

cavity zone to a downwind distance of approximately ten (10) building heights from the

structure. If a pollutant plume is entrained within these regions, nearby impact

concentrations can be higher than in the absence of such effects. GEP also

represents the maximum stack height allowable for a given source (beyond which

additional dispersion credit is not acceptable) when conducting an air quality impact

modeling analysis.

29



As a part of this dispersion modeling analysis, the USEPA-approved Building Profile

Input Program -Prime (BPIPPRM Version 04274) was used for comparing the actual

stack height for each source with its GEP stack height. In the instance where the

actual stack height occurs below the GEP height, the BPIP program also calculates the

appropriate direction-specific building dimensions for each wind direction (10-degree

increments). This information is used by the AERMOD dispersion model to calculate

the effects of the site-specific building downwash (cavity and wake effects) on ambient

concentrations and the overall dispersion of the plume.

3.3.13 Meteorological Data

Careful consideration was given to selecting a location from which to obtain

meteorological data to ensure the data is representative of conditions at the proposed

project site. Complete meteorological data, collected at the San Juan International

Airport station for the last five consecutive years (2005 to 2009) was obtained. Both

the surface and upper air levels were available for this location. Additionally, one year

of historical data (August 1992 to August 1993) was available from the Puerto Rico

Energy Power Authority (PREPA) in Cambalache which has a meteorological station

within one mile of the subject site in Arecibo. PREPA data were used in conjunction

with the San Juan data from the 1992-1993 timeframe for completion of this modeling

analysis. The San Juan meteorological data were determined to be reasonably

representative of the proposed site. This was important in order to format and compile

the 1992-1993 PREPA Cambalache meteorological data for use in the AERMOD

modeling. The PREPA Cambalache data included wind direction, wind speed,

temperature, and solar radiation. To complete the PREPA Cambalache meteorological

data set so that it could be used in AERMOD, it was necessary to add data

representing cloud cover, ceiling height, pressure, and relative humidity. Data were

extracted from the 1992-1993 meteorological data set collected in San Juan for this

purpose.

Surface and upper air input files for AERMOD were prepared using the AERMET

processor programs. The inputs to AERMET for surface characteristics (surface

roughness, Albedo and Bowen ratio) were determined based on land use in the area

surrounding the anemometer site.

3.3.14 Land Use and Dispersion Coefficients

Electronic land use data that are available through the USGS for Puerto Rico are not

considered representative of the current conditions. Therefore, per USEPA direction,

30



the AERSURFACE utility was not be used for this project. Rather, surface roughness

numbers were calculated per the ADEC Guidance for AERMET Geometric Means,

which was developed by the State of Alaska. This guidance provides the equations

needed to calculate the surface roughness numbers for inclusion in AERMET. This

guidance essentially replicates the procedure followed by AERSURFACE utility

program, but with the land use data determined through satellite images and

photographs. The surface roughness calculated is representative of the sites where

the meteorological data were collected: Cambalache, Arecibo, Puerto Rico (Latitude:

18.471553°; Longitude: -66.701673°) and Luis Munoz Marin International (SJU)

Airport, San Juan, Puerto Rico (Latitude: 18.437484°; Longitude: -66.002791°).

Twelve equal sectors were evaluated for two six-month periods; summer conditions

(wet season) and winter conditions (dry season).

Based on climatological patterns for Puerto Rico, the region experiences two seasons:

(1) a wet season from May through October, and (2) a dry season from November

through April. During the wet season, the vegetation is lush and trees contain full

foliage. For this reason, the Bowen ratio, albedo, and surface roughness values from

the AERSURFACE guidance Mid Summer category were selected. During the dry

season, scrubland vegetation and most trees maintain their foliage. However, most

crop areas have been harvested and deciduous trees lose some foliage due to lack of

water. Therefore, the Late Spring Category values from the AERSURFACE guidance

were selected for the surface characteristics for the dry season.

In determining surface roughness coefficients, land use conditions out to a distance of

one kilometer were assessed. The Bowen ratio and albedo were determined based on

land use conditions out to a distance of 10 kilometers. The resulting surface

characteristics are presented in Table 3-7 below.

31



Table 3-7 Surface Characteristics for the Cambalache Site for Summer and Winter Seasons

Sector (degrees) Bowen Ratio Albedo Surface Roughness

0-30 0.107 (0.107) 0.102 (0.102) 0.155 (0.154)

30-60 0.127 (0.127) 0.107 (0.107) 0.201 (0.201)

60-90 0.405 (0.368) 0.157 (0.157) 0.192 (0.154)

90-120 0.311 (0.229) 0.160 (0.160) 0.176 (0.125)

120-150 0.847 (0.636) 0.172 (0.172) 0.285 (0.216)

150-180 0.693 (0.432) 0.173 (0.173) 0.172 (0.125)

180-210 0.655 (0.434) 0.172 (0.172) 0.117 (0.066)

210-240 0.646 (0.428) 0.172 (0.172) 0.111 (0.059)

240-270 1.263 (1.192) 0.178 (0.178) 0.167 (0.139)

270-300 0.156 (0.155) 0.110 (0.110) 0.032 (0.030)

300-330 0.100 (0.100) 0.100 (0.100) 0.009 (0.009)

330-360 0.100 (0.100) 0.100 (0.100) 0.007 (0.007)

Selection of the appropriate dispersion coefficients for air quality modeling is

determined using the USEPA-preferred land use classification technique in 40 CFR 51,

Appendix W (also known as the “Auer” technique). This classification technique

involves assessing land use for Auer’s categories within a three (3) kilometer radius of

the site (Auer 1978). USEPA recommends using urban dispersion coefficients and

mixing heights if greater than 50 percent of the area is urban; otherwise, rural

coefficients and mixing heights apply. Based on an evaluation of land use in the

vicinity of the site, approximately 20 percent of the area within three (3) kilometers is

urban while rural land use constitutes approximately 80 percent. See Figure 3-1 for an

aerial view of the study area with the surrounding land use identified. Based on the

land use observed, the “rural” dispersion parameter is selected for this analysis.

32



3.3.15 Receptor Arrays

Coarse and dense grid receptor arrays were used to evaluate potential impacts. The

dense grid is a Cartesian system that covers of 8 km by 8 km in area centered at the

proposed project location. Receptors are located at the project boundary and extend

outward in all directions. Receptor spacing from the project boundary is as follows:

• Inner grid = 25 m spacing out to a distance of 200 m;

• Second grid = 50 m spacing out to a distance of 400 m;

• Third grid = 100 m spacing to 0.5 km;

• Fourth grid = 500 m spacing out to a distance of 4 km;

• Outer grid = 1,000 m spacing out to a distance of 8 km.

The coarse grid also includes a polar coordinate grid extending out to 24 km from the

center of the project location. Grid radials will be spaced every ten degrees and

rings will be placed at 1-km intervals beginning 2 km from the project location center.

Receptor elevations were assigned using the USEPA’s AERMAP software tool

(version09040; USEPA 2009), which is designed to extract elevations from USGS

National Elevation Dataset (NED) data at 1 degree (approximately 30 m) resolution

in GeoTIFF format (USGS 2002). While 7.5-minute DEM data would be preferable

as the 7.5-minute data provide better resolution, these data are not available for

Puerto Rico. The one degree datum is acceptable internationally and adequately

captures changes in elevation such as the mountain southwest of the subject site.

AERMAP, the terrain preprocessor for AERMOD, uses interpolation procedures to

assign elevations to a receptor. As a quality check procedure, a topographic map of

the model region was generated from AERMAP elevations; this map was compared

with the most recent available topographic maps to ensure accurate representation

of terrain features were captured during the processing of AERMAP.

3.3.16 Air Quality Modeling Results

Table 3-8 lists the maximum modeled ambient air concentration for CO, PM10, PM2.5,

NO2, and SO2 for all proposed emission sources in comparison with the PSD Class II

Significant Impact Level (SIL). Two operating scenarios were modeled based on100%

normal operating level and 110% peak operating level.

33



Table 3-8 Significant Impact Levels Evaluation

1. NO2 concentration estimated as 75% of the NOx predicted by modeling based on EPA Guidance for

the Tier II NO2 calculation method (EPA, 2010).

Modeled concentrations below the SIL indicate that potential emissions will not cause

or contribute to a violation of the NAAQS or PSD increment. Values shown for CO,

PM10 and PM2.5 were found to be below their respective SIL, and no further analysis

is required. Maximum modeled concentrations were found to exceed the one-hour SIL

for SO2 and NO2. Concentrations of NO2 and SO2 were below the SIL for all other

averaging times. Consequently, this evaluation includes a limited cumulative analysis

in order to evaluate whether the NAAQS could potentially be exceeded for the1 hour

NO2 and SO2 averaging period.

The limited cumulative impact analysis required that emissions from additional nearby

major sources of SO2 and NO2 be included in the analysis. Energy Answers, with the

assistance of PR EQB, collected emissions data from nearby emission sources and

found that the nearest emission source that would likely influence the cumulative one-

hour air quality impacts is the Puerto Rico Electric Power Authority (PREPA)

Cambalache facility. The maximum permitted emission rates at the PREPA

Cambalache plant were modeled using actual stack parameters and coordinates

Parameter Averaging Period

Maximum

Concentration

(µg/m3)

Class II SIL

(µg/m3)

UTM

Northing

(meters)

UTM

Easting

(meters)

CO

1 High 136 2000 746602 2036551

8 High 35 500 742658 2042988

PM10 24 High 4.3 5 742527 2042426

Annual High 0.85 1 742527 2042426

PM2.5 24 High 0.54 1.3 741561 2036624

Annual High 0.10 0.3 741663 2042191

SO2

1 High 49.8 8 742602 2035551

3 High 16.6 25 742602 2035551

24 High 3.45 5 741561 2036624

Annual High 0.64 1 741663 2042191

NO2 1

1 High 68 8 742739 2042949

Annual High 0.89 1 742637 2042975

34



obtained from EQB. When modeling cumulative impacts, AERMOD was used with the

same input specifications as described above. However, where the maximum impact

is used for comparison to the SIL, the impacts representing the 98th and 99

th percentile

were used for the 1-hour NO2 and SO2 for comparison to the NAAQS. Results of this

analysis are tabulated below.

Table 3-9 Model Results – Cumulative Impact Levels

1. NO2 concentration estimated as 75% of the NOx predicted by modeling based on EPA Guidance for

the Tier II NO2 calculation method (EPA, 2010). 1 hour NO2 Concentration reported is the 8th

highest, representing the 98th percentile of the annual daily maximum 1 hour concentrations to show

compliance with the NAAQS.

Based on these results, emissions from the proposed facility are expected to result in

ambient concentrations that are below the NAAQS for NO2 and SO2. To date, there

are no PSD increments for the one-hour NO2 and SO2 averaging periods. Emissions

of PM10, PM2.5 and CO are estimated to result in ambient concentrations that are

below the Significant Impact Level (SIL).

3.4 Summary of Air Quality Impacts

The results of this analysis indicate that the impacts during the construction phase of

the project for the partial-build and build alternatives would be minor for during

construction. The potential impacts from construction are temporary, short-term,

localized increases in ambient concentrations that are prevalent in the active

construction area. Long-range transport of pollutants during construction is not likely to

occur to any quantifiable degree because the emissions are generated near ground

level, whether they originate from the internal combustion engines of the construction

equipment or from the dust-generating actions associated with clearing, excavation,

grading or paving.

Parameter Averaging Period

Maximum

Concentration

(µg/m3)

Background

Ambient

Concentration

(µg/m3)

Total Ambient

Concentration

(µg/m3)

NAAQS

(µg/m3)

SO2 1 High 41.3

86.5 128 195

NO2 1 High 1011 72 173 188

35



Potential air quality impacts during the facility operating phase are predicted to be

below the PSD SIL thresholds for all but NO2 and SO2 on a 1-hour average.

Therefore, these potential impacts can be considered insignificant and no further

analysis is required. For the 1-hour NO2 and SO2, a limited cumulative impact

analysis was completed, including the PREPA Cambalache facility located near the

project site. Results of the cumulative impact analysis indicate that the 1-hour NAAQS

for NO2 and SO2 will not be exceeded. Therefore, the potential impacts to air quality

from the proposed facility are not considered significant.

36



4. References

United States Environmental Protection Agency (USEPA). Guidance for Estimating

Natural Visibility Conditions Under the Regional Haze Rule. EPA-454/B-03-005.

September 2003.

USEPA. 1995. AP-42, Compilation of Air Pollutant Emission Factors, Volume 1,

Stationary Point and Area Sources. January.

Auer, August H. Jr. 1978: “Correlation of Land Use and Cover with Meteorological

Anomalies.” Journal of Applied Meteorology, pp 636-643. 1978.

PREQB, 1993. “Source Specific Acidic Deposition. Impacts for Permit Applications,”

L. Sedefian. March 4.

PREQB. 1997. Policy DAR-1: Guidelines for the Control of Toxic Ambient Air

Contaminants. November.

PREQB. 2006. PREQB DAR-10: Guidelines on Dispersion Modeling Procedures for

Air Quality Impact Analyses. May.

Schulman, et al. 1997. “The PRIME Plume Rise and Building Downwash Model,”

Addendum to ISC3 User’s Guide. November.

United States Environmental Protection Agency (USEPA). 1980. “A Screening

Procedure for the Impacts of Air Pollution Sources on Plants, Soils and

Animals.” EPA 450/2-81-078. December 12.

USEPA. 1987. Ambient Monitoring Guidelines for Prevention of Significant

Deterioration, EPA-450/4-87-007. Revised May 1987. Research Triangle

Park, NC.

USEPA. 1990. Draft EPA NSR Workshop Manual: PSD and NonAttainment Area

Permitting Manual. October.

USEPA. 1995. User's Guide To The Building Profile Input Program. EPA-454/R-93-

038. Revised February 8, 1995.

http://www.dec.ny.gov/chemical/30681.html

http://www.dec.ny.gov/chemical/30681.html

37



USEPA. 1996. PCRAMMET User’s Guide. EPA-454/B-96-001. OAQPS, Research

Triangle Park, NC.

USEPA. 2000. Meteorological Monitoring Guidance for Regulatory Modeling

Applications. EPA-454/R-99-005. OAQPS, Research Triangle Park, NC.

USEPA. 2004a. User's Guide for the AMS/EPA Regulatory Model – AERMOD. EPA-

454/B-03-001. September.

USEPA. 2004b. User's Guide For The AERMOD Terrain Preprocessor (AERMAP).

EPA-454/B-03-003. October.

USEPA. 2005. Guideline on Air Quality Models. November.

USEPA. 2008. AERSURFACE User’s Guide. EPA-454/B-08-001. OAQPS,

Research Triangle Park, NC.

USEPA. 2010a. Notice Regarding Modeling for New Hourly NO2 NAAQS. Office of

Air Quality Planning and Standards (OAQPS), Air Quality Modeling Group

(AQMG). February 25.

USEPA. 2010b. Modeling Procedures for Demonstrating Compliance with PM2.5

NAAQS. Office of Air Quality Planning and Standards (OAQPS).

Memorandum from Stephen D. Page to Regional Air Division Directors dated

March 23, 2010.

USEPA. 2010c. Guidance Concerning Implementation of the 1-hour NO2 NAAQS for

the Prevention of Significant Deterioration Program. Office of Air Quality

Planning and Standards (OAQPS). Memorandum from Stephen D. Page to

Regional Air Division Directors dated June 29, 2010.

USEPA. 2010d. Guidance Concerning the Implementation of the 1-hour SO2 NAAQS

for the Prevention of Significant Deterioration Program. Office of Air Quality

Planning and Standards (OAQPS). Memorandum from Stephen D. Page to

Regional Air Division Directors dated August 23, 2010.

United States Geological Survey (USGS). 2002. The National Map – Elevation, Fact

Sheet 106-02. http://egsc.usgs.gov/isb/pubs/factsheets/fs10602.html, U.S.

Department of the Interior. November.

Figures

SITE LOCATION

P u e r t o R i c oP u e r t o R i c o

Aguada

Aguadilla

Añasco

Cabo RojoLajas

Mayagüez

Moca

Rincón

San Germán

Adjuntas

Aibonito

Arecibo

Arroyo

Barranquitas

Bayamón

Caguas

CamuyCarolina

Cayey

Ceiba

Ciales

Cidra

Coamo

Comerío

Corozal

Dorado

FajardoFlorida

Guánica

Guayama

Guayanilla

Gurabo

Hatillo

Humacao

Isabela

Jayuya

Juana Díaz

Juncos

Lares

Las Marías

Loíza

Luquillo

Manatí

Maricao

Maunabo

Morovis

Naguabo

Naranjito

Orocovis

Patillas

Peñuelas

Ponce

Río Grande

Salinas

San Juan

San Lorenzo

San Sebastián

Santa Isabel

Toa Alta

Toa Baja

Utuado

Vega Baja

Villalba

YabucoaYauco

FIGURE

1

PROJECT LOCATION MAP

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ENERGY ANSWERSARECIBO, PUERTO RICO

STORM WATER

DETENTION POND

1

2A2B

3

4

6

8

9A

10

11

12

19A

14

15A 15B

16A 16B

17A 17B

18A 18B

19B20

22A 22B 21

13

STORM WATER

DETENTION POND

WATER STORAGE

POND

23

EX

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BU

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ELEVATED VISITOR

TOUR STRUCTURE

24

25A 25B

26

P-1A

P-2

P-6P-5

P-7

P-8

P-10

P-11 P-12 P-13 P-14

P-1B

P-3

P-9

5A

5B

9B

27

P-4

P-15

NO. LEGEND AND LOCATION SCHEDULE VENT LOCATION SCHEDULE

STRUCTURE VENT NO. ELEVATION

(METERS)

COORDINATES

METERS* DEGREES*

1 WEIGH STATION

2A MSW RECEIVING AREA

2B MSW PROCESSING AREA

3 PRF STORAGE AREA

4 ASH PROCESSING AREA

5A BOTTOM ASH TRANSFER AREA

6 POWER BLOCK BUILDING

7 SWITCHYARD

8 CAFETERIA, TRAINING & LOCKER ROOMS

9A BOILER 1

10 WATER TANK

11 PAC SILO

12 LIME SILO

13 FLYASH STABILIZATION SILO

14 FLYASH SILO

15A SDA 1

15B SDA 2

16A BAGHOUSE 1

16B BAGHOUSE 2

17A ID FAN 1

17B ID FAN 2

18A RSCR 1

18B RSCR 2

19A BOOSTER FAN 1

19B BOOSTER FAN 2

20A STACK FLUE - BOILER 1

21 AMMONIA SKID

22A RAW WATER STORAGE TANK 1

22B RAW WATER STORAGE TANK 2

23 ADMINISTRATION BUILDING

24 COOLING TOWER (4 CELLS)

25A WATER STORAGE TANK

25B WATER STORAGE TANK

26 STORAGE / WAREHOUSE

P-1B

P-2

P-5

P-7

P-8

P-10

P-3

P-1A 15.2

12.2

30.5

18.2

5B BOTTOM ASH TRANSFER AREA P-4

10.7

18.2

P-9 13.1

30.5

14.6

38.1

106.7

10.7

9B BOILER 2

20B STACK FLUE - BOILER 2 P-6 106.7

27 CONCRETE PRODUCTS BUILDING

FOR DISPERSION MODEL PURPOSES COORDINATES ARE GIVEN IN TERMS OF METERS

FROM THE NW CORNER OF THE EXISTING PAPERMILL AND DEGREES

COUNTERCLOCKWISE FROM TRUE EAST. *

130.9116

116.9924

132.3847

204.6976

192.2018

233.0714

71.72

87.74

159.52

232.72

194.47

224.33

P-15

169.4434 205.84

178.9684 206.28

187.833 213.59

184.8358 224.44

181.7878 225.07

106.4514 183.88

COOLING TOWER (4 CELLS)



24

24

24

P-11

P-12

P-13

P-14

97.409 183.17

88.3666 182.33

79.3496 181.29

182.5244 210.32

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Attachment 1 Emission Calculations

Attachment 1

PRELIMINARY DRAFT ENERGY ANSWERS ARECIBO

BOILER POTENTIAL EMISSIONS AND STACK PARAMETERS

ARECIBO PUERTO RICO

Parameter Units MAX TYPICAL

Fuel Firing Rate TPD 1155 1050

Heat Input MMBTU/hr 550 500

% Load Capacity % 110 100

Estimated Flue Gas Conditions

Stack Gas Temperature F 317 316

Flue Gas Flow (wet) lb/hr 630267 572970

Flue Gas Flow (dry) lb/hr 635728 577935

Flue Gas Flow (wet) acfm 248540 225945

Flue Gas Flow (dry) dscfm 134415 122196

Flue Gas Flow (dry) dscmm 3806 3460

Stack Inner Diameter ft 7 7

Velocity fps 107.64 97.85

MODEL EMISSION RATE

BACT Limit / MAX AVG MAX AVG

Pollutant Emission Factor Units g/s g/s lb/hr lb/hr TPY (1)

PM 10 mg/DSCM @ 7% O2 0.634 0.577 5.03 4.58 20.0

PM10 10 mg/DSCM @ 7% O2 0.634 0.577 5.03 4.58 20.0

PM2.5 10 mg/DSCM @ 7% O2 0.634 0.577 5.03 4.58 20.0

NOx 45 ppmvd @ 7% O2 5.46 4.97 43.36 39.42 172.7

SO2 24 ppmvd @ 7% O2 4.06 3.69 32.20 29.27 128.2

CO 150 ppmvd @ 7% O2 11.09 10.08 87.98 79.98 350.3

VOC 0.016 lbs/MMBtu 1.11 1.01 8.80 8.00 35.0

HCl 25 ppmvd @ 7% O2 2.41 2.19 19.11 17.38 76.1

Mercury 17 ug/DSCM @ 7% O2 1.08E-03 9.80E-04 0.0086 0.0078 0.034

Nickel 0.000063 lbs/ton PRF 3.82E-04 3.47E-04 0.0030 0.0028 0.012

Arsenic 0.00000517 lbs/ton PRF 3.13E-05 2.85E-05 0.00025 0.00023 0.000991

Cadmium 10 ug/DSCM @ 7% O2 6.34E-04 5.77E-04 0.0050 0.0046 0.0200

Chromium 0.0000407 lbs/ton PRF 2.47E-04 2.24E-04 0.0020 0.0018 0.0078

Lead 75 ug/DSCM @ 7% O2 0.0048 0.0043 0.038 0.034 0.150

TCDD-2378 13 ng/DSCM @ 7% O2 8.25E-07 7.50E-07 6.54E-06 5.95E-06 2.61E-05

Beryllium 0.00000073 lbs/MMBtu 0.000051 0.000046 4.02E-04 3.65E-04 0.00160

Fluorides (as HF) 0.0032 lbs/MMBtu 0.222 0.202 1.76 1.60 7.01

Sulfuric acid (as H2SO4) 0.014 lbs/MMBtu 0.970 0.882 7.70 7.00 30.7

Ammonia 20 ppmvd @ 7% O2 0.90 0.82 7.12 6.47 28.4

Example Calculations:

PM10 : 10 mg/DSCM x 3460 DSCMM x 1 g/1000 mg x 1 min / 60 sec = 0.577 g/s

SO2 : 24 ppmvd x 122196 ft / min x 1 ppm / 1,000,000 x 1 lb-mol / 385 ft3 x 64.04 lb SO2/lb-mol x 453.6 g/lb x 1 min / 60 sec = 3.69 g/s

Sulfuric acid : 0.014 lb/MMBtu x 500 MMBtu/hr x 453.6 g/lb x 1 hr / 3600 sec = 0.882 g/s

Nickel : 0.000063 lb/ton PRF x 1050 ton/day x 1 day/24 hr x 1 hr/3600 sec x 453.6 g/lb = 3.74 E-4 g/s

Notes:

(1) Annual Emissions are based on the average operating condition (100% load) occurring continously for 8,760 hours per year.

Attachment 1

ENERGY ANSWERS ARECIBO

POTENTIAL EMISSIONS AND STACK PARAMETERS

ARECIBO PUERTO RICO

COOLING TOWER

One cooling tower with four cells will be used as follows:

Number of Cooling Towers 1 (with 4 cells per unit)

Recirculation Rate 65150 gpm

Make-up Water 1016 gpm

Cycles of Concentration of Cooling Water 5.00

TDS in Make-Up 3000.00 ppmw

Drift Eliminator Efficiency 0.0005 %

TDS in Cooling Water 3000 ppmw

Predominant dissolved solids in cooling water NaCl

Density of Primary DS 2.165 g/cm3

Per AP-42, Chapter 13.4 the following equation is used for estimating PM emissions from the cooling tower.

Total PM = Circulating flow x Drift Rate x TDS in cooling water

This equation combined with the values listed above provide the following PM emission values:

Total PM emissions = 0.0154 g/s Per Cell in the CT

Total PM emissions = 0.122 lbs/hr Per Cell in the CT

Total PM emissions = 0.54 tons/year Per Cell in the CT

5

Volume of drift droplet =

Mass of solids in drift droplet =

Mass of solids in drift droplet =

The fraction of total particulate matter which is equal to or less than 10 microns (PM10) and 2.5 microns (PM2.5) are

estimated based on a methodology developed by Reisman and Frisbie. This methodology was developed for use with

cooling towers that use ocean water, so the primary particulate used in their calculations was sodium chloride (salt).

Assuming the solids remain and coalesce after the water evaporates, the mass of solids can also be

expressed as:

3

234

⋅Π⋅ dD

3

234

⋅Π⋅⋅⋅ d

w

DTDS ρ

3

234

⋅Π⋅⋅ d

TDS

Dρ

Attachment 1



ARECIBO PUERTO RICO

COOLING TOWER

Solving the previous two equations for Dp then gives:

Where: TDS = concentration of Total Dissolved Solids, in ppmw

Dp = diameter of solid particle (after evaporation), in microns (µm)

Dd = diameter of drift droplet (before evaporation), in microns (µm)

rw = density of water droplet, 1.0 g/cm3

rTDS = density of solid particle, in g/cm3

EPRI Droplet

Diameter (µm)

Droplet

Volume

(µm3)

Droplet Mass

(mg)

Particle Mass

Solids (mg)

Solid

Particle

Volume

(µm3)

Solid

Particle

Diameter

(µm)

EPRI % Mass

Smaller than

PM10 (10 µm)

10 524 5.24E-04 1.57E-06 0.73 1.1 0.000

20 4,189 4.19E-03 1.26E-05 5.8 2.2 0.196

30 14,137 1.41E-02 4.24E-05 20 3.3 0.226

40 33,510 3.35E-02 1.01E-04 46 4.5 0.514

50 65,450 6.54E-02 1.96E-04 91 5.6 1.816

60 113,097 0.1 3.39E-04 157 6.7 5.702

70 179,594 0.2 5.39E-04 249 7.8 21.348

90 381,704 0.4 1.15E-03 529 10.0 49.812

110 696,910 0.7 2.09E-03 966 12.3 70.509

130 1,150,347 1.2 3.45E-03 1,594 14.5 82.023

150 1,767,146 1.8 5.30E-03 2,449 16.7 88.012

180 3,053,628 3.1 9.16E-03 4,231 20.1 91.032

210 4,849,048 4.8 1.45E-02 6,719 23.4 92.468

240 7,238,229 7.2 2.17E-02 10,030 26.8 94.091

270 10,305,995 10.3 3.09E-02 14,281 30.1 94.689

300 14,137,167 14.1 4.24E-02 19,590 33.4 96.288

350 22,449,298 22.4 0.1 31,108 39.0 97.011

400 33,510,322 33.5 0.1 46,435 44.6 98.340

450 47,712,938 47.7 0.1 66,115 50.2 99.071

500 65,449,847 65.4 0.2 90,693 55.7 99.071

600 113,097,336 113.1 0.3 156,717 66.9 100.000

PM30 = 94.7%

PM10 = 49.8%

PM2.5 = 0.20% (estimated using linear interpolation)

Using the conservative estimate of the calculated PM diameter immediately greater than the PM fraction of

interest, the Brentwood Industries study values above show the following breakdown of total PM:

Recreating Tables 1 and 2 from the Resiman and Frisbie document for the facility's specific TDS

concentration gives the following new table:

3

⋅⋅=

TDS

wdp TDSDD

ρρ

Attachment 1



ARECIBO PUERTO RICO

COOLING TOWER

g/s lb/hr TPY

PM30 = 0.015 0.116 0.51 per cell

PM10 = 0.00767 0.061 0.27 per cell

PM2.5 = 3.13E-05 0.00025 1.1E-03 per cell

Therefore, only the fractions of total PM calculated for cooling tower emissions corresponding with the values

listed above will be used in the facility's emission estimates. Applying these percentages to the total annual

emissions calculated above provide the following PTE values for various PM size distributions:

Attachment 1


ARECIBO PUERTO RICO

LIME AND ASH HANDLING

Energy Answers will operate ash handling and storage facilities. Each potential source will be controlled using a baghouse.

Filter performance specification taken from USEPA's Environmental Technology Verification for Bahouse Filtration Products of QG061 Filtration Media,

manufactured by GE Energy.

PM10

Flow Rate Flow Rate Filter spec

Description Source ID Vent ID m3/s cfs grains/acf Material lb/s g/s lb/hr TPY

Bottom Ash Handling Conveyor Trans1 P-3 9.45 334 0.001 Nomex / BHA-TEX 4.77E-05 0.0216 0.172 0.75

Bottom Ash Handling Conveyor Trans2 P-4 9.45 334 0.001 Nomex / BHA-TEX 4.77E-05 0.0216 0.172 0.752

Ash Processing Bldg Ash P-15 28.16 995 0.001 Nomex / BHA-TEX 1.42E-04 0.0645 0.512 2.241

Lime Storage Silo Silo 2 P-7 0.473 16.7 0.001 Nomex / BHA-TEX 2.39E-06 0.00108 0.0086 0.038

Flyash Storage Silo Silo 4 P-8 0.473 16.7 0.001 Nomex / BHA-TEX 2.39E-06 0.00108 0.0086 0.038

Activated Carbon Storage Silo Silo 1 P-9 0.473 16.7 0.001 Nomex / BHA-TEX 2.39E-06 0.00108 0.0086 0.038

PM2.5

Flow Rate Flow Rate Filter spec

Description Source ID Vent ID m3/s cfs g/dscm Material lb/s g/s lb/hr TPY

Bottom Ash Handling Conveyor Trans1 P-3 9.45 334 0.000017 Nomex / BHA-TEX 3.54E-07 1.61E-04 0.001 0.01

Bottom Ash Handling Conveyor Trans2 P-4 9.45 334 0.000017 Nomex / BHA-TEX 3.54E-07 1.61E-04 0.001 0.006

Ash Processing Bldg Ash P-15 28.16 995 0.000017 Nomex / BHA-TEX 1.06E-06 4.79E-04 0.004 0.017

Lime Storage Silo Silo 2 P-7 0.473 16.7 0.000017 Nomex / BHA-TEX 1.77E-08 8.04E-06 0.0001 0.0003

Flyash Storage Silo Silo 4 P-8 0.473 16.7 0.000017 Nomex / BHA-TEX 1.77E-08 8.04E-06 0.0001 0.0003

Activated Carbon Storage Silo Silo 1 P-9 0.473 16.7 0.000017 Nomex / BHA-TEX 1.77E-08 8.04E-06 0.0001 0.0003

Attachment 1

ENERGY ANSWERS ARECIBOPotential Emissions Calculations

Emergency Diesel Generator (670 hp)

Engine Power Output = 670 hp

Annual Operating Time = 500 hours

Emission Factor Emission Rate Emission Rate Annual Emissions Annualized

Pollutant g/bhp-hr lb/hr g/s lb/yr TPY

PM NSPS LIMIT 0.15 0.22 0.028 111 0.0554

PM10 NSPS LIMIT 0.15 0.222 0.028 111 0.0554

PM2.5 NSPS LIMIT 0.15 0.222 0.028 111 0.0554

SO2 NSPS LIMIT 0.002 0.0030 0.00037 1.48 0.000739

NOx NSPS LIMIT 3.0 4.43 0.56 2,216 1.11

VOC NSPS LIMIT 0.15 0.22 0.028 111 0.055

CO NSPS LIMIT 2.61 3.86 0.486 1,928 0.96

HAP

Acetaldehyde 3.86E-07 5.71E-07 7.19E-08 0.0003 1.43E-07

Acrolein 5.52E-08 8.15E-08 1.03E-08 0.00004 2.04E-08

Arsenic 2.94E-08 4.34E-08 5.47E-09 0.0000 1.09E-08

Benzene 5.43E-06 8.02E-06 1.01E-06 0.00401173 2.01E-06

Benzo(a)pyrene 1.80E-09 2.66E-09 3.35E-10 0.0000013 6.64E-10

Beryllium 1.75E-08 2.58E-08 3.26E-09 0.0000129 6.46E-09

Cadmium 7.70E-08 1.14E-07 1.43E-08 0.00006 2.84E-08

Chromium 4.03E-07 5.95E-07 7.49E-08 0.0003 1.49E-07

Chromium (VI) 0.00E+00 0.00E+00 0.00E+00 0.000000 0.00E+00

Ethylbenzene 2.23E-07 3.30E-07 4.16E-08 0.000165 8.25E-08

Fluoride 1.02E-05 1.50E-05 1.89E-06 0.00750 3.75E-06

Formaldehyde 5 5.52E-07 8.16E-07 1.03E-07 0.00041 2.04E-07

Lead 6.23E-08 9.20E-08 1.16E-08 0.00005 2.30E-08

Manganese 9.80E-08 1.45E-07 1.82E-08 0.00007 3.62E-08

Mercury 2.10E-08 3.10E-08 3.91E-09 0.00002 7.75E-09

Methyl Chloroform 6.44E-08 9.51E-08 1.20E-08 0.00005 2.38E-08

Naphthalene 9.10E-07 1.34E-06 1.69E-07 0.00067 3.36E-07

Nickel 1.26E-07 1.86E-07 2.35E-08 0.00009 4.65E-08

POM 1.48E-06 2.19E-06 2.76E-07 0.00110 5.48E-07

Toluene 1.97E-06 2.91E-06 3.66E-07 0.00145 7.26E-07

Xylenes 1.35E-06 2.00E-06 2.51E-07 0.00100 4.99E-07

Notes:

1) Emission factors taken from AP-42 "Compilation of Air Pollutant Emission Factors", 5th edition, Tables 3.4-3 and 3.4-4, and 40 CFR 89 Subpart B Table 1.

2) Conservatively, 100 percent of TSP is assumed to be PM-2.5.

3) Fuel Sulfur content not to exceed 15 parts per million (per NSPS Subpart IIII and 40 CFR 80.510(b)).

4) NSPS Limit is given in terms of NOx + Nonmethane Hydrocarbon (VOC). VOC is assumed to be 5% by weight.

5) AP-42 Emission Factors for HAP are converted to lb/hp-hr assuming 7,000 Btu/hp-hr as noted in Table 3.3-1.

Attachment 1


Fire Water Pump (335 hp)

Engine Power Output = 335 hp

Annual Operating Time = 500 hours

Emission Factor Emission Rate Emission Rate Annual Emissions

Pollutant g/bhp-hr lb/hr g/s lb/yr TPY

PM NSPS LIMIT 0.15 0.11 0.014 55.4 0.0277

PM10 NSPS LIMIT 0.15 0.111 0.014 55.4 0.0277

PM2.5 NSPS LIMIT 0.15 0.111 0.014 55.4 0.0277

SO2 NSPS LIMIT 0.002 0.0015 0.00019 0.74 0.000369

NOx NSPS LIMIT 3.0 2.22 0.28 1,108 0.554

VOC NSPS LIMIT 0.15 0.11 0.014 55 0.028

CO NSPS LIMIT 2.61 1.93 0.243 964 0.482

HAP

Acetaldehyde 5.37E-06 3.97E-06 5.00E-07 0.0020 9.91E-07

Acrolein 6.48E-07 4.78E-07 6.03E-08 0.00024 1.20E-07

Benzene 6.53E-06 4.82E-06 6.08E-07 0.0024 1.21E-06

Benzo(a)pyrene 1.32E-09 9.72E-10 1.22E-10 0.00000049 2.43E-10

1,3-Butadiene 2.74E-07 2.02E-07 2.55E-08 0.0001011 5.05E-08

Ethylbenzene 2.23E-07 1.65E-07 2.08E-08 0.0000825 4.12E-08

Fluoride 1.02E-05 7.50E-06 9.45E-07 0.00375 1.87E-06

Formaldehyde 8.26E-06 6.10E-06 7.69E-07 0.0031 1.53E-06

Methyl Chloroform 6.44E-08 4.76E-08 5.99E-09 0.000024 1.19E-08

Naphthalene 5.94E-07 4.38E-07 5.52E-08 0.000219 1.10E-07

POM 1.18E-06 8.69E-07 1.09E-07 0.00043 2.17E-07

Propylene Oxide 5 1.81E-05 1.33E-05 1.68E-06 0.0067 3.33E-06

Toluene 2.86E-06 2.11E-06 2.66E-07 0.00106 5.29E-07

Xylenes 2.00E-06 1.47E-06 1.86E-07 0.000737 3.68E-07

Notes:

1) Emission factors taken from AP-42 "Compilation of Air Pollutant Emission Factors", 5th edition, Table 3.3-2 and 40 CFR 60 Subpart IIII Table 4.

2) Conservatively, 100 percent of TSP is assumed to be PM-2.5.

3) Fuel Sulfur content not to exceed 15 parts per million (per NSPS Subpart IIII and 40 CFR 80.510(b)).

4) NSPS Limit is given in terms of NOx + Nonmethane Hydrocarbon (VOC). VOC is assumed to be 5% by weight.

5) AP-42 Emission Factors for HAP are converted to lb/hp-hr assuming 7,000 Btu/hp-hr as noted in Table 3.3-1.

Attachment 1


500 MMBTU/hr Boilers During Startup

Firing No. 2 Fuel Oil

No. 2 Fuel Oil Heating Value: 140000 BTU/gal

Max Fuel Use Rate - 100% load: 3,571 Gal/hour (EACH BOILER)

Annual Max Fuel Usage: 180,000 Gal/yr

Emission Uncontrolled Control Controlled Controlled Annual Emissions

Factor Emission Rate Efficiency Emission Rate

Pollutant lb/1000 gal lb/hr % lb/hr lb/yr TPY

PM 3.30 11.79 99 0.118 5.9 0.0030

PM10 1.00 3.571 99 0.036 2 0.0009

PM2.5 0.25 0.893 99 0.00893 0 0.0002

SO2 21.3 76.0714 80 15.2 766.80 0.383400

NOx 24.0 85.71 80 17.1 864 0.43

VOC 0.20 0.71 0 0.714 36 0.018

CO 5.00 17.86 0 17.9 900 0.45

HAP

Arsenic 5.60E-04 2.00E-03 99 2.00E-05 0.0010 5.04E-07

Benzene 2.75E-03 9.82E-03 0 9.82E-03 0.49500000 2.48E-04

Beryllium 4.20E-04 1.50E-03 99 1.50E-05 0.0007560 3.78E-07

Cadmium 4.20E-04 1.50E-03 99 1.50E-05 0.00076 3.78E-07

Chromium 4.20E-04 1.50E-03 99 1.50E-05 0.0008 3.78E-07

Ethylbenzene 8.17E-04 2.92E-03 0 2.92E-03 0.147112 7.36E-05

Fluoride 3.73E-02 1.33E-01 80 2.66E-02 1.34280 6.71E-04

Formaldehyde 4.80E-02 1.71E-01 0 1.71E-01 8.64000 4.32E-03

Lead 5 1.26E-03 4.50E-03 99 4.50E-05 0.00227 1.13E-06

Manganese 8.40E-04 3.00E-03 99 3.00E-05 0.00151 7.56E-07

Mercury 4.20E-04 1.50E-03 70 4.50E-04 0.02268 1.13E-05

Methyl Chloroform 2.36E-04 8.43E-04 0 8.43E-04 0.04248 2.12E-05

Naphthalene 3.33E-04 1.19E-03 0 1.19E-03 0.05994 3.00E-05

Nickel 4.20E-04 1.50E-03 99 1.50E-05 0.00076 3.78E-07

POM 3.30E-03 1.18E-02 0 1.18E-02 0.59400 2.97E-04

Selenium Compounds 2.10E-03 7.50E-03 99 7.50E-05 0.00378 1.89E-06

Toluene 7.97E-02 2.85E-01 0 2.85E-01 14.34112 7.17E-03

Xylenes 1.40E-03 5.00E-03 0 5.00E-03 0.25213 1.26E-04

Notes:

1) Emission factors taken from AP-42 "Compilation of Air Pollutant Emission Factors", 5th edition, Chapter 1.3.

Attachment 1


ARECIBO PUERTO RICO

Annual Emissions Summary - TPY

Cooling

PSD Major

Source

Pollutant Boiler 1 Boiler 2 Ash Handling Silos EDG FWP Tower Total TPY

PM 20.0 20.0 3.74 0.113 0.055 0.0277 2.03 46.1 100

PM10 20.0 20.0 3.74 0.113 0.055 0.0277 1.07 45.1 100

PM2.5 20.0 20.0 3.74 0.113 0.055 0.0277 0.0044 44.0 100

NOx 173 173 --- --- 1.11 0.55 --- 347 100

SO2 128 128 --- --- 0.0007 0.00037 --- 256 100

CO 350 350 --- --- 0.96 0.48 --- 702 100

VOC 35.0 35.0 --- --- 0.055 0.0277 --- 70.2 100

HCl 76.1 76.1 --- --- --- --- --- 152 ---

Mercury 0.0341 0.0341 --- --- 7.75E-09 --- --- 0.0682 0.1

Nickel 0.0121 0.0121 --- --- 4.65E-08 --- --- 0.024 ---

Arsenic 0.00099 0.00099 --- --- 1.09E-08 --- --- 0.0020 > 0

Cadmium 0.0200 0.0200 --- --- 2.84E-08 --- --- 0.040 ---

Chromium 0.00780 0.00780 --- --- 1.49E-07 --- --- 0.016 ---

Lead 0.150 0.150 --- --- 2.30E-08 --- --- 0.30 0.6

TCDD-2378 2.61E-05 2.61E-05 --- --- --- --- --- 5.21E-05 3.50E-06

Beryllium 0.0016 0.0016 --- --- 6.46E-09 --- --- 0.0032 0.0004

Fluorides (as HF) 7.01 7.01 --- --- --- 1.87E-06 --- 14.0 3

Sulfuric acid (as H2SO4) 30.7 30.7 --- --- --- --- --- 61.3 7

Ammonia 28.4 28.4 --- --- --- --- --- 56.7 ---

Attachment 2 Air Modeling Files

estudio de impacto a la calidad del aire ambientaldeclaración de impacto ambiental –preliminar...

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